Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
InvITs may add back, in calculating net distributable cash flows at both HoldCo/SPV and Trust levels, payments for major maintenance of road projects funded by external borrowings. This exception to the general prohibition on debt-funded cash distributions requires prior unitholder approval for each relevant project, including approval for additional borrowing beyond an approved proposal. Major maintenance must be non-routine expenditure required by the concession agreement. Statutory auditor certification, specified disclosures on borrowing, debt maturity, NDCF and distribution impacts, and disclosures of funding alternatives are required. The revised framework takes effect immediately.
InvITs may add back, in calculating net distributable cash flows at both HoldCo/SPV and Trust levels, payments for major maintenance of road projects funded by external borrowings. This exception to the general prohibition on debt-funded cash distributions requires prior unitholder approval for each relevant project, including approval for additional borrowing beyond an approved proposal. Major maintenance must be non-routine expenditure required by the concession agreement. Statutory auditor certification, specified disclosures on borrowing, debt maturity, NDCF and distribution impacts, and disclosures of funding alternatives are required. The revised framework takes effect immediately.
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